Fresh Ideas Emerge for New EU Budget Levies

This paper examines the taxation of income earned by social media influencers and other digital content creators, focusing on tax compliance, informal digital labor, and cross-border income. Focusing on Indonesia, it considers income from advertising revenue sharing, sponsored content, affiliate commissions, and virtual gifts, as well as the limitations of existing domestic withholding mechanisms. The paper also examines how U.S. tax withheld by foreign platforms on income attributable to American viewers creates cross-border foreign tax credit and documentation issues for Indonesian creators, and proposes platform-based information reporting and clearer guidance on foreign-source income.

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This article analyzes the structural, political, and operational implications of the OECD Pillar Two Side-by-Side Package released in January 2026. It examines the new Simplified ETR and Substance-Based Tax Incentive Safe Harbours, the extension of the Transitional CbCR Safe Harbour, and the Side-by-Side and UPE Safe Harbours, including their interaction with the IIR, UTPR, and QDMTTs. The author questions whether these measures meaningfully simplify the GloBE Rules and argues that their interaction with domestic tax systems may increase compliance costs, litigation, and implementation asymmetries.

Citation: Latin American Tax Policy Forum (LATPF) Post, January 2026.

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This paper examines how Mexican labor, tax and financial law would apply to employer-provided AI token budgets and proposes a four-level framework based primarily on how freely employees may use the tokens. Tokens restricted to work purposes would constitute work tools rather than salary, while tokens available for personal use would constitute in-kind benefits forming part of salary and taxable income. Transferable tokens usable as payment could potentially qualify as virtual assets under Mexico’s Fintech Law if they are not denominated in currency, although the paper concludes that AI tokens cannot themselves constitute money or replace wages required to be paid in legal tender.

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This General Report examines the function of corporate tax residence across domestic income tax systems and tax treaties, drawing on branch reports prepared for the International Fiscal Association’s 2025 Lisbon Congress. It identifies substantial variation in domestic approaches involving incorporation, governance and other residence criteria, alongside a trend toward expanding the scope of corporate residence. At the treaty level, the report finds that most treaties still use place of effective management as a tie-breaker but identifies a progressive shift toward mutual agreement procedures, which the author argues creates uncertainty because corporate residence often determines exposure to worldwide taxation.

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This article examines the 15 percent minimum effective tax rate and controlled foreign company rules introduced by the Nigeria Tax Act 2025. It analyzes the Act’s treatment of certain undistributed profits of controlled foreign companies and the imposition of top-up tax where relevant foreign subsidiaries are taxed below the prescribed minimum ETR, comparing these rules with income-inclusion concepts and the OECD/G20 Pillar Two framework. The authors emphasize that, although Nigeria’s regime resembles aspects of the GloBE Rules, Nigeria remains outside the Inclusive Framework’s Two-Pillar Solution and has adopted a distinct domestic regime.

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This work examines changes in international corporate taxation from 2008 to 2021, culminating in the October 2021 agreement establishing a two-pillar framework and a 15 percent country-by-country minimum effective corporate tax rate. It analyzes how the 2008 financial crisis and COVID-19 pandemic contributed to reform through G20 and OECD initiatives and examines the role of the Transnational Tax Policy Community in shaping the international tax agenda. The author also argues that domestic politics significantly affect implementation and enforcement, highlighting the continuing tension between multilateral tax cooperation and national sovereignty.

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This paper examines Article 12AA of the 2025 UN Model Tax Convention, which grants source-based taxing rights over imported cross-border services regardless of the service provider’s physical presence. It argues that the provision can help developing countries address base erosion and simplify tax collection by complementing traditional physical-nexus rules and reducing the need for complex service classifications. The paper also considers the challenge of translating the new provision into practical tax administration.

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This paper examines how six types of tax incentives interact with Pillar Two and the Qualified Domestic Minimum Top-up Tax by simulating their post-QDMTT effective tax rates using a common GloBE Income base. It finds that income-based exemptions and non-qualified tax credits are compressed toward the 15% minimum rate, while qualified refundable tax credits generally preserve more incentive value because they are treated as GloBE Income rather than reductions of Covered Taxes. Accelerated depreciation produces an intermediate result because its effect is primarily one of timing rather than a permanent tax difference.

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This article examines whether the proposed global minimum corporate tax can adequately address corporate tax arbitrage and argues that deficiencies in international tax dispute resolution may complicate its implementation. It calls for strengthening the mutual agreement procedure and examines the potential conflict between national tax sovereignty and investor protections under investor-state dispute settlement, particularly as minimum-tax rules are implemented through domestic legislation. The author argues that reconciling these regimes is important to addressing investment disputes that could challenge the implementation of BEPS 2.0.

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This article examines the effectively connected income rules governing foreign persons engaged in a U.S. trade or business and identifies two features that can distort the determination of U.S. business income. The authors argue that the U.S.-office-or-other-fixed-place-of-business requirement can underinclude income generated by U.S. business activities, while the residual force-of-attraction rule can overinclude income. They propose eliminating the USFPB requirement for determining the ECI status and source of certain income, as well as the residual force-of-attraction rule, to more accurately capture income generated by foreign persons’ U.S. business activities.

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